Perhaps OK. But you did not indicate the date of your first SEPP distribution last October. Even if the distribution was dated 10/1/2009, it is recommended that you add a couple days to the 5 year period for a safety margin. If your first distribution was later in October, then you modification date would also be later in October, 2014.A different issue is your options for distributions in your final stub year of 2014. All the modification date means is that distributions prior to that date must comply with SEPP requirements, while after that date your plan has ended and there are no restrictions. So you also will need to decide in 2014 how much you will withdraw PRIOR to the modification date. Your choices will be:1) A full annual distribution2) 3/4 of an annual reflecting September as the month for which you must take a distribution3) Take nothing, BUT ONLY if you took out 12 months worth in 2009, and would therefore have taken out 5 years of distributions by year end 2013. Finally, it is somewhat risky to take out your full annual in January because it puts alot of budget pressure on you. If you spend too much too fast and run dry prior to year end, you risk having to take a plan busting extra distribution. Besides, in today's environment you are not going to earn much in the way of interest for the period between your distribution and spending that distribution. 4 quarterly distributions in the first week of each quarter is better, but as long as you know the risks and deal with it you should be OK.